Treaty detail
United Kingdom - Austria tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2018-10-23
Effective
2019-03-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 0%
The 2018 UK-Austria treaty provides a zero-percent rate for qualifying corporate parent-subsidiary cases and 15 percent more broadly, with article-level qualifying conditions and beneficial-ownership tests.
Interest
Rate: 0%
The 2018 treaty generally eliminates source-country withholding on interest. Beneficial-ownership and anti-abuse tests still apply, including the MLI principal-purpose-test overlay.
Royalties
Rate: 0%
The treaty generally applies a zero rate to qualifying royalties across major categories. The article definition controls characterization for mixed contracts.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent rules reflect modern post-BEPS wording. The principal-purpose-test overlay applies to qualifying treaty modifications between the UK and Austria.
Other treaty flags
Private pensions are generally taxable only in the residence state under the modern UK-Austria treaty. Government-service pensions and lump sums follow separate rules and should be reviewed against the article text.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the prerequisite for every reduced rate or business-profit protection.
Residence under the modern UK-Austria treaty includes contemporary tiebreaker rules and reflects post-BEPS developments. Dual-residence questions are resolved using the article's tiebreaker mechanism.
Article 5
Permanent Establishment
Defines the source-country business-presence threshold.
Article 5 reflects modern OECD post-BEPS wording. The construction threshold and agent-based rules incorporate updates relevant to the principal-purpose-test environment introduced by the MLI.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment.
Business-profits relief is the practical operating rule for cross-border services and trading between the UK and Austria. Once a PE exists, attribution rules apply as updated by the modern treaty.
Article 10
Dividends
Provides reduced and zero-percent rates for qualifying cross-border dividends.
The 2018 dividend article provides modern qualifying-condition language and supports a zero rate for qualifying parent-subsidiary cases, with 15 percent more broadly.
Article 11
Interest
Generally removes source-country withholding on qualifying interest.
Interest payments between the UK and Austria are common in intercompany financing. The zero rate is the headline and the article-level beneficial-ownership tests apply.
Article 12
Royalties
Generally removes source-country withholding on qualifying royalties.
The royalty article applies a zero rate to qualifying payments across major categories. The article-level definition governs characterization for mixed contracts.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
- TreatyGB–NL treaty
Primary sources
- HMRC Austria tax treaties pageVerified 2026-05-20
- Austrian Federal Ministry of Finance (BMF) treaty listVerified 2026-05-20
- OECD MLI signatories and partiesVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.